Recent California Court of Appeal Decision Makes It Harder To Fight Copycat Class Actions

The California Court of Appeal has issued a published decision holding that denial of class certification in one lawsuit may not prevent similar class action claims in a later lawsuit.  On January 18, 2012, in Bridgeford v. Pacific Health Corporation, the court expressly disagreed with a prior Court of Appeal decision from the same district that held collateral estoppel could prevent class actions that are similar to prior cases where class certification was denied.

In Bridgeford, the plaintiffs filed a class action complaint against Pacific Health Corporation and other hospitals and health care entities for various violations of California’s wage and hour laws.  The defendants demurred to the complaint on the grounds that the plaintiffs were collaterally estopped from seeking class certification because class certification was denied in a prior action that involved the same causes of action and subclasses that were similar to those in Bridgeford.  The trial court sustained the defendants’ demurrer in Bridgeford on these grounds and dismissed the plaintiffs’ complaint in its entirety. 

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